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Pacific Southwest, Region 9

Serving: Arizona, California, Hawaii, Nevada, Pacific Islands, Tribal Nations

Hawaii Nonpoint Source Program:
Review of the Implementation Plan

EPA's Review of the Hawaii Implementation Plan for the Polluted Runoff Program, Based on the Nine Key Elements that the State Must Meet to Obtain Approval of its Upgraded Clean Water Act Section 319 Program

Prepared by Audrey Shileikis, U.S. EPA Region 9, September 2000


On July 28, 2000, the Department of Health (DOH) and the Office of Planning (OP) submitted to EPA the final Hawaii Implementation Plan for the Polluted Runoff Program (Implementation Plan) dated July 2000. EPA reviewed the Implementation Plan to determine if the nine key elements, as defined in the Nonpoint Source Program and Grant Guidance for FY 1997 and Beyond (May 1996), are addressed and has determined that the State has successfully addressed the nine key elements. We are recommending approval, pursuant to the Clean Water Act (CWA).

Hawaii has integrated the Coastal Nonpoint Control Program (CNPCP) under Coastal Zone Act Reauthorization Amendments (CZARA) with its Polluted Runoff Program under the CWA and has established a single upgraded and integrated Implementation Plan. This plan includes the 15-year program strategy and 5-year implementation plan for the achievement of CZARA management measures. Although the approval processes for the Nonpoint Source Upgrade (CWA) and the CZARA programs are distinct, the specific environmental protection measures overlap. EPA and NOAA will continue to work with the State to address the conditions for approval of the Coastal Nonpoint Pollution Control Program under CZARA in the future.

The State is to be commended for this integration and for the level of public outreach and participation during the development of this program. The Implementation Plan provides the needed framework to guide the continued development and implementation of the Polluted Runoff Program in Hawaii.


The Implementation Plan sets the stage for the Polluted Runoff Program by describing what nonpoint sources of pollution are, helping the reader understand more about Hawaii's unique environment, and where the most significant water quality problems are. Following is a summary of how the nine key elements are addressed.

Key Element #1: The State program contains explicit short-and long-term goals, objectives and strategies to protect surface and ground water.

The Implementation Plan provides a vision and mission statement, three long-term goals with corresponding short-term goals, action items with time frames, and measures of success. Most noteworthy among its long-term goals include Hawaii's commitment to restore designated uses in impaired water bodies within 15 years; complete Total Maximum Daily Loads (TMDL) for section 303(d) listed waters by 2012; and to develop and implement CZARA management measures within 15 years.

Hawaii also developed a well-organized "phased approach" for implementing its program activities in five year increments. For example, Hawaii follows a three-phased approach (completing Phase I by 2003, Phase II by 2008, and Phase III by 2013) to:

  • target a specific set of priority watersheds based on the Unified Watershed Assessment to develop and implement watershed management plans in five year increments;
  • implement Watershed Restoration Action Strategies and test the effectiveness of Best Management Practices in five year increments;
  • to implement a particular number of management measures (from Coastal Zone Act Reauthorization Amendments (CZARA)) in five year increments.

    Key Element #2: The State strengthens its working partnership and linkages to appropriate State, interstate, Tribal, regional and local entities (including conservation districts), private sector groups, citizen groups and federal agencies.

    Partnerships are critical to effective implementation of the Nonpoint Source Program. Hawaii has established a positive interagency relationship between the Department of Health (with jurisdiction over the 319 program) and the Office of Planning (with jurisdiction over the CZARA program), and has formalized this relationship in a MOA allowing for a more coordinated approach to implementing their respective programs. Hawaii has also developed a number of Statewide partnerships, including diverse groups of public and private stakeholders, and has engaged these groups to develop program goals (e.g., through its Environmental Management Advisory Group), to provide technical advice and guidance (e.g., through its Technical Committee for NPS), and to solicit input regarding the development and implementation of its program (e.g., through its Polluted Runoff Forum and focus groups).

    Hawaii has also participated in a number of watershed-based partnerships, with specific purposes to implement a particular MOU established within the watershed, to develop and implement specific water quality improvement projects, and to develop and implement Watershed Restoration Action Strategies (WRAS) to improve coastal water quality (see Table 3-2). Additionally, for its five priority watersheds (targeted for restoration within the first five years), Hawaii has identified the lead organization and key partners it is engaging in each watershed (see Table 5-3). However, due to staff changes and workload concerns since the finalization of this report, the capacity of several of the Soil and Waters Conservation Districts (SWCDs) to lead this effort is limited. The State has issued a request for proposal to identify another entity to lead the effort to develop a WRAS for three of the five priority watersheds. The State does anticipate the continued participation of the SWCDs in these watershed efforts.

    The State is also seeking opportunities to involve more diverse stakeholder groups through either statewide or watershed partnerships (i.e., Polluted Runoff Forum, focus groups, Ala Wai, W. Maui, Environmental Management Advisory Group, and specific projects with the hotel and golf industries).

    Key Element #3: The State uses a balanced approach that emphasizes both statewide nonpoint source programs and on-the-ground management of individual watersheds where waters are impaired or threatened.

    The Implementation Plan outlines a statewide approach to controlling polluted runoff that includes coordination between water quality programs and targeting resources. This applies to programs within DOH, as well as with the CZARA program which focuses on sectors (agriculture, urban, forestry, marinas, hydromodification, wetlands) and relies upon other federal, state and local agencies to implement key activities. This includes programs like water quality standards, monitoring, Unified Watershed Assessments, total daily maximum loads, BMP implementation through Section 319 grants and other agencies' programs (i.e., county ordinances, Conservation District Use Area permits, etc.), NPDES permits, 401 certifications, source water protection, ground water, education, outreach, Coral Reef Initiative, and programs under the USDA (EQIP, WHIP). This also includes participating in statewide forums as described under key element #2.

    The State's watershed approach flows from the statewide process of identifying priority watersheds through the Unified Watershed Assessment to the more local level by providing funding and technical support to these local watershed efforts. The state is using a phased approach (five year cycles) to systematically address the category one watersheds - those in need of restoration. For Phase 1, the state has identified five category one watersheds that will receive Section 319 funds to implement existing watershed plans (Pelekane Bay, W. Maui) or to develop watershed restoration action strategies to guide future funding (S. Molokai, Nawiliwili, Koolaupoko). To the extent possible, these efforts will be coordinated with the TMDL program to either generate information to do TMDLs or implement TMDLS.

    Additionally, Hawaii describes two other watershed-level efforts (in the Ala Wai watershed and the West Maui watershed) that can serve as models for future community-based projects in other watersheds (see P. 5-6). Accomplishments identified in the West Maui project include implementation of many urban and agricultural BMPS; a revised Erosion and Sediment Control ordinance for all of Maui; and a 60% reduction in nitrogen and phosphorous loadings to wastewater injection wells. This management plan will provide a basis for implementing successful NPS programs in watersheds throughout the State.

    Key Element #4: The State program (a) abates known water quality impairments from nonpoint source pollution and (b) prevents significant threats to water quality from present and future nonpoint source activities.

    The Implementation Plan identifies a combination of regulatory and non-regulatory activities to abate known water quality impairments and prevent threats to water quality. These activities are discussed under key element #3, identified in the Coastal Nonpoint Pollution Control Plan (under CZARA) and in this Implementation Plan. The State program focuses funding and activities on priority watershed based on the State 305b report, Section 303(d) list, and the Unified Watershed Assessment.

    Hawaii also recognizes the importance of preventing significant threats to water quality from new or expanding activities by providing funding for pollution prevention projects and activities, such as the Pollution Prevention Program for Hotels in Maui; education and outreach efforts; development of a management measure for golf courses; and participating in a Pollution Prevention Committee.

    Key Element #5: The State program identifies waters and watersheds impaired by nonpoint source pollution and identifies important unimpaired waters threatened or at risk. Further, the State establishes a process to progressively address these identified waters by conducting more detailed watershed assessments and developing watershed implementation plans, and then by implementing the plans.

    The Implementation Plan specifically identifies the use of the 305 b assessment report to assess waters and to target priority water bodies based on the use of the State's 303d list and the Unified Watershed Assessment. Specifically Hawaii's prioritization process targets the top five priority watersheds as identified in the State's UWA within the first five years, and the second tier Category I watersheds within 10 years, and any additional watershed regions in need of restoration within 15 years (P. 2-1 1). The State's priority watersheds were selected through a collaborative process with other agencies that ranked the State's watersheds based upon a set of criteria that include consideration of whether the watershed drains into a 303(d)-listed waterbody and the likelihood of success in engaging watershed partners. The five priority watersheds will receive incremental Section 319 funds to develop and/or implement a watershed restoration action strategy. Base Section 319 funding can also be targeted to waters on the State's 303(d) list.

    Key Element #6: The State reviews, upgrades, and implements all program components required by section 319(b) of the Clean Water Act, and establishes flexible, targeted, and iterative approaches to achieve and maintain beneficial uses of water as expeditiously as practicable.

    The State prepares an annual report or end-of-year evaluation that summarizes accomplishments and slippages of the grant-funded activities over the last year. This report is the basis for EPA and State annual program evaluations and discussions of activities to improve program implementation.

    The State plans to update the Implementation Plan every five years. They will evaluate the progress toward reaching the goals in this plan and develop the next 5-year implementation plan. This evaluation will be based on water quality monitoring data, information from implementation of statewide and watershed specific projects, and annual evaluations.

    Key Element #7: The State identifies Federal lands which are not managed consistently with State nonpoint source program objectives. Where appropriate, the State seeks EPA assistance to help resolve issues.

    While the Federal government owns only 8.4 percent of Hawaii's lands, the State has identified several approaches to ensuring that Federal lands and activities are managed consistently with the Polluted Runoff Program. Examples include: 1) the State's Coastal Zone Management Program's review of federal programs and activities for consistency with State programs; 2) the State's participation in an erosion control subcommittee of the Federal Family Committee Meetings (Clean Water Action Plan); and 3) the State's participation in the Department of Defense's process to develop new national discharge standards for vessels and the Navy's development of a Federal Integrated Natural Resource Management Plan. The State will use partnership forums (Chapter 3) and Federal Consistency review meetings to address polluted runoff issues on federal lands.

    Key Element #8: The State manages and implements it nonpoint source program efficiently and effectively, including Financial management.

    The State's effective management and implementation of the NPS program is very important in achieving environmental goals and demonstrating accountability for federal and State funds. The State has described the components of their planning, management, and evaluation system that includes: annual work plan development; project solicitation, oversight, and implementation for on-the-ground projects and for development and implementation of Watershed Restoration Action Strategies; program evaluations (annual work plan accomplishments and 5year program effectiveness); and program reporting.

    Hawaii describes a well-designed approach to Statewide and watershed activities that are focused on critical areas. Financial, program, and project activities are tracked, evaluated, and reported.

    Key Element #9: The State periodically reviews and evaluates its nonpoint source management program using environmental and functional measures of success, and revised its nonpoint source assessment and management program at least every five years.

    Hawaii has incorporated a feedback loop into its management plans with a commitment to update its management plan every five years based upon an evaluation of progress toward reaching its long-term goals. The State will base its 5-year evaluation on water quality monitoring data and information from the implementation of Statewide and watershed-based projects. This feedback loop is dependent on a monitoring program that assesses the effectiveness of BMPs and the program. Hawaii presents a checklist of activities that it will use to evaluate program progress, as well as specific schedules for preparing 5-year implementation plans (see section 4.8.2).

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